TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Addition made towards interest expenses claimed - assessee derived income from letting out the properties i.e. rental income, which has been shown as income from operations in the P&L Account - As the interest expenses incurred on the borrowing which are utilized for acquiring the assets, income derived from which is credited to P&L account and offered to tax. There is a direct nexus between the income offered and the expenditure claimed. - AT
Addition made towards interest expenses claimed - assessee derived income from letting out the properties i.e. rental income, which has been shown as income from operations in the P&L Account - As the interest expenses incurred on the borrowing which are utilized for acquiring the assets, income derived from which is credited to P&L account and offered to tax. There is a direct nexus between the income offered and the expenditure claimed. - AT
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